New waste management regulations effective Wednesday, March 15, 2023 include changes that apply to dental offices. This is a wholesale rewrite and reorganization of the medical waste regulations, implemented to improve the handling and treatment of regulated medical waste. The full regulations can be found in the Virginia Register of Regulations. Virginia Dental Association counsel Ben Traynham, with Hancock and Daniel, shared some elements in the regulations of note for dental offices:

1. “exposed ends of dental wires,” culture slides, and culture dishes are now explicitly included in the definition of “sharps” and shall be exposed of in sharps containers.
2. Records of regulated medical waste (RMW) treatment or shipment to offsite facility shall be maintained for 3 years by the generator.
3. Generators of less than 250 gallons of RMW per calendar month (I assume all dental practices) must arrange for removal of such waste at least once per calendar month. No RMW may be stored for more than 45 calendar days.  Generators of more than 250 gallons must arrange for removal once a week.
4. The regulation specifies that dental amalgam is not considered regulated medical waste provided it is managed in accordance with the federal dental rule.
5. The definition of “storage” was updated to include all generators of RMW; whereas, previously it only applied to generators of 200+ gallons of RMW. There is a whole new section regarding storage, requiring RMW to be stored in a manner that maintains integrity of packaging, minimize potential for spills, is clean and orderly, and meets packaging and labeling requirements in the regulation.
6. New rules pertaining to reusable RMW containers to ensure properly disinfected
7. New rules on how to handle spills of RMW—anyone handling RMW shall have a spill containment and cleanup kit onsite within the vicinity of where RMW is stored/managed. Such a kit must include material designed to absorb any liquids, one gallon of EPA-registered hospital grade disinfectant in a spray container, enough red plastic bags to enclose at least 150% of the RMW managed at the site, and relevant PPE.

Regulated Medical Waste Management Regulations